December 10, 2013

Jared Blumenfeld

U.S. EPA Regional Administrator

74 Hawthorne Street

San Francisco, CA 94105

SUBJECT: PROPOSED ATTAINMENT/UNCLASSIFIABLE PM2.5DESIGNATION FOR THE PALA BAND OF MISSION

INDIANS RESERVATION.

Thank you for the opportunity to submit a designation recommendation for the area under the Pala

Band of Mission Indians jurisdiction for the 2012 Annual PM25 National Ambient Air Quality Standard

(NAAQS). The goals of the Pala Band of Mission Indians are to maintain good air quality, strive to

protect the air resources for future generations, and exercise our inherent sovereign authority over our

air shed as provided in sections 301(d) and 110(o) of the Clean Air Act. Pala recommends that the lands

within the exterior boundaries of the reservation remain designated as an attainment/unclassifiable

area for the 2012 Annual PM25 NAAQS. Below are the reasons for the basis of our request:

JURISDICTIONAL BOUNDARIES

The Pala Indian Reservation is located in the central northern part of the San Diego County Air Basin

(SDCAB) and is within the jurisdiction of the San Diego County Air Pollution Control District (SDCAPCD).

The SDCAB and SDCAPCD cover San Diego County only. Two other air basins adjoin the San Diego

County Air Basin. These are the South Coast Air Basin to the northwest and the Salton Sea Air Basin to

the east and northeast. Emissions from these two adjoining air basins could impact the air quality in the

SDCAB, particularly the Reservation area. Winds associated with seasonal weather fronts could bring

emissions from neighboring air basins into the SDCAB. However, the air quality in the rural parts of the

SDCAB, including the reservation, is generally quite good due to several factors including low population

and a lack of major industries or stationary sources.

GEOGRAPHIC AREA

The terrain within the Reservation boundary varies from relatively flat land with elevations of

approximately 200 feet above mean sea level to very steep terrain with elevations greater than 3,000

feet above mean sea level. The spectrum of elevations within the Reservation is due in part to the

mountain range of the Cleveland National Forest, which is located within the northeastern portion of

the Reservation.
TRAFFIC AND COMMUTING PATrERNS

US Interstate 15 is a major commuter corridor between San Diego County in the south and Riverside

County to the north. Traffic volumes are heavy and contribute to the overall deterioration of air quality.

US-15 is located seven miles west of the Pala Reservation. Prevailing winds blow from the Southwest

toward the reservation. The Pauma Valley is narrow and affords a limited area of exposure to

commuter traffic pollution. California State Highway 76 crosses the Reservation from east to west. Caltrans traffic volume counts show a peak hourly volume of 1,200 vehicles. Vehicles using SH-76 are a mixof local residents, visitors to the casinos and limited commuter traffic.

GROWTH RATES AND PATTERNSOverall the growth rate in San Diego County is declining, both numerically and percentage-wise. Theslowed growth rate county-wide is in response to out-migration by those seeking more affordable

housing. Of the 12,449 acres within the Reservation only 2,639 are fee lands which have strict

regulations governing their disposition. Land development and concurrent population growth on the

Pala Reservation is strictly regulated by the U.S. Department of Interior, Bureau of Indian Affairs in

concert with the Pala Band of Mission Indians, and not subject to the same developmental pressures as

privately held lands elsewhere. With a total tribal population of 924 there is little demand for

development at the present time. With significant growth restraints, air quality deterioration on the

reservation should remain unchanged in the foreseeable future.

METEOROLOGICAL DATA

The Pala reservation is east of the coastal range and has a fairly mild climate that does not experiencegreat temperature variations between winter and summer. The area experiences temperatures that are

comfortably mild in the winter and persistently warm throughout the summer. The prevailing winddirection blows from the South-Southwest toward the Northeast region of the reservation at an average

of 4 36 miles per hour.

EMIssIoNs DATA

An Emissions Inventory (El) of the various pollution sources within the reservation’s exterior boundaries

was updated in 2010. It was found in this inventory that the majority of our PM2.5 emissions are

produced from traffic on SH-76 and US-15. Not only are there no significant PM2.5emitting facilities

present on the reservation, but our design value shows we fall under the new standard of 12 .tg/m 3 See

air quality data section below.
PM2.5annual standard of 12 .tg/m 3(see data below).

YEAR ANNUAL AVERAGE

2010 8.82011 9.9

2012 9.8

DESIGN VALUE 95

Because our design value is 9.5 ig/m 3,well below the standard, we respectfully request that the Pala

Indian Reservation remain designated as unclassifiable/attainment for the 2012 annual PM2.5NAAQS.

Thank you for your attention to this matter.

If you have any questions regarding this recommendation please contact:

Shasta Gaughen Pala Environmental Director 760-891-3515

Rodney Watkins Pala Air Quality Specialist 760-891-3511

Frank Spurgeon Pala Air Technician 760-891-3540

Robert H. Smith

Tribal Chairman